People v. Currie

2025 IL App (5th) 220578-U
Procedural entryThis page is a short order in People v. Currie. Read the opinion of the Court — 237 N.E.3d 981
Appellate Court of Illinois·Decided October 6, 2025·No. 5-22-0578·Unpublished

Opinion

NOTICE 2025 IL App (5th) 220578-U NOTICE Decision filed 10/06/25. The This order was filed under text of this decision may be NO. 5-22-0578 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the

Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Trial Court of Plaintiff-Appellee, ) Macon County. ) v. ) No. 12-CF-829 ) ERIC A. CURRIE, ) Honorable ) James R. Coryell, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE BOIE delivered the judgment of the court. Justices Barberis and Vaughan concurred in the judgment.

ORDER

¶1 Held: We affirm the judgment of the trial court denying defendant’s postconviction petition after a third-stage evidentiary hearing where the defendant failed to demonstrate prejudice due to ineffective assistance of counsel.

¶2 The defendant, Eric A. Currie, pleaded guilty on February 18, 2014, to one count of

unlawful possession with the intent to deliver 100 grams or more, but less than 400 grams, of a

controlled substance, after having been previously convicted of unlawful possession of a controlled

substance in violation of section 401(a)(2)(B) of the Illinois Controlled Substances Act (720 ILCS

570/401(a)(2)(B) (West 2012)). The defendant was sentenced on April 17, 2014, to 15 years’

incarceration within the Illinois Department of Corrections.

¶3 The defendant filed a postconviction petition pursuant to the Post-Conviction Hearing Act

(Act) (725 ILCS 5/122-1 et seq. (West 2016)), on April 18, 2017. After a third-stage evidentiary 1 hearing on August 12, 2022, the trial court denied the defendant’s petition and the defendant now

appeals. For the following reasons, we affirm the judgment of the trial court.

¶4 I. BACKGROUND

¶5 On February 18, 2014, the defendant was scheduled to stand trial. The defendant was

represented by Baku Patel (defense counsel), who did not appear on the day of trial and instead,

sent his associate, Dennis Steeves (plea counsel), to appear and request a continuance due to on-

going plea negotiations. The State objected, indicating that it was ready to proceed, and the trial

court denied the request for a continuance since the matter had been pending for almost two years.

The matter then proceeded with jury selection.

¶6 Prior to jury selection, plea counsel informed the trial court that the defendant had

witnesses he intended to call, but that he only had the moniker of one of the witnesses and did not

know the witness’s legal name. The State indicated that it was unaware of two of the defense’s

witnesses since those witnesses had not been previously disclosed. The trial court indicated that it

would read the witnesses’ name to the jury, but withhold its ruling on whether the two witnesses

would be barred from testifying at trial until the State had an opportunity to speak with the

witnesses. As such, the trial court indicated that the jury would be selected, but not sworn, so that

jeopardy would not be attached. Plea counsel then participated in selecting a jury.

¶7 Later that afternoon, the trial court was informed that there was a disposition in the case,

and the matter was recalled. Plea counsel informed the trial court that the defendant would be

entering an open plea to a single count of unlawful possession, and that the remaining counts

contained in the charging instrument would be dismissed. The trial court proceeded with

admonishments regarding an open plea, and when advising the defendant of the minimum and

maximum sentence, informed the defendant that it was a 40-year maximum period of

2 incarceration. The State informed the trial court that, although the charging instrument stated 40

years, it should have stated 80 years because of the prior conviction. The State then indicated that

it would not seek an extended term sentence, and the trial court informed the defendant that the

maximum sentence remained at 40 years. The trial court then continued its admonishments,

including informing the defendant that he did not have to plead guilty and could proceed to trial

the next day. The defendant acknowledged his understanding of each right and then pleaded guilty

to one count of unlawful possession with the intent to deliver a controlled substance (720 ILCS

570/401(a)(2)(B) (West 2012)).

¶8 On March 21, 2014, the defendant filed a pro se “Motion to Take my plead Back,” that

stated that the defendant felt “as if I was force[d] too [sic] take a plead [sic] of guilty.” The

defendant withdrew his pro se motion at his sentencing hearing on April 17, 2014, and was

sentenced to 15 years’ incarceration and 3 years of mandatory supervised release.

¶9 On May 22, 2014, the defendant filed a pro se motion for reduction of sentence and a pro se

motion to withdraw his guilty plea and vacate his sentence. Both motions alleged, inter alia,

ineffective assistance of counsel. The State filed a motion to dismiss the defendant’s post-sentence

pleadings arguing that the pleadings were filed beyond the 30-day requirement of Illinois Supreme

Court Rule 604(d) (eff. Feb. 6, 2013). On July 9, 2015, the trial court conducted a hearing and

denied the defendant’s post-sentence pleadings finding that the motions were untimely. The

defendant appealed and the appeal was dismissed. People v. Currie, No. 4-15-0592 (2015)

(unpublished order under Illinois Supreme Court Rule 23(c)). 1

1 The mandate of the appellate court stated that the appeal was dismissed, but does not state the basis of the dismissal. According to the defendant’s brief, that appeal was dismissed owing to the absence of any timely post-sentencing motions. 3 ¶ 10 The defendant filed a postconviction petition pursuant to the Act (725 ILCS 5/122-1 et seq.

(West 2016)), on April 18, 2017. On May 18, 2017, the trial court appointed counsel to represent

the defendant, and counsel was granted leave to withdraw on December 20, 2017. 2 The trial court

appointed new counsel who, after requesting numerous continuances, filed an amended petition

on February 27, 2019.

¶ 11 The State filed a motion to dismiss the amended petition on May 29, 2019. The trial court

conducted a hearing on June 21, 2019, and found that the defendant’s affidavit was not “in

compliance with Supreme Court rules dealing with affidavits.” As such, the trial court granted the

State’s motion to dismiss with leave for the defendant to file a second amended petition, with a

proper affidavit, within 90 days. 3

¶ 12 On December 10, 2021, the defendant filed a motion for leave to file a late second amended

petition. The trial court granted the defendant’s motion for leave on January 6, 2022, and the

defendant’s second amended petition was filed instanter. 4 The defendant’s second amended

petition alleged ineffective assistance of counsel in that defense counsel failed to file a motion to

withdraw the defendant’s guilty plea as requested by the defendant; failed to challenge the

voluntariness of the defendant’s confession; unreasonably coerced the defendant into pleading

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